> ---------- > From: panupdates@igc.apc.org[SMTP:panupdates@igc.apc.org] > Sent: Monday, February 08, 1999 3:34 PM > To: panups@igc.apc.org > Subject: PANUPS: Action alert: Risks to birds > > ===================================== > P A N U P S > *** > Pesticide Action Network > North America > Updates Service > http://www.panna.org/panna/ > email panna@panna.org > ===================================== > > February 8, 1999 > > Action Alert: Cotton Pesticide Poses Reproductive Risks to Birds > > The American Bird Conservancy's Pesticides and Birds Campaign urges > the scientific, conservation and advocacy communities to call on the > U.S. Environmental Protection Agency (EPA) to deny registration of > the insecticide chlorfenapyr because of reproductive risks to birds. > Chlorfenapyr has been characterized by EPA as "one of the most > reproductively toxic pesticides to avian species that Environmental > Fate and Effects Division has evaluated." Because of the agency's > concerns regarding ecological risks, EPA's Office of Pesticide > Programs has opened a public comment period through February 19. > > American Cyanamid has proposed use of chlorfenapyr (brand names > Pirate and Alert) as an insecticide and miticide on cotton. It is > touted as one of the most effective controls available for beet > armyworm in chemically intensive cotton agriculture. Applications > for use on citrus and vegetables and for termites and ants are also > pending. Chlorfenapyr belongs to a new class of chemical called > "pyrrole" -- never before registered by EPA. When metabolized, it > acts on the mitochondria and disrupts production of ATP (adenosine > triphosphate), leading to cell death and, ultimately, mortality. > > The following ecological concerns are detailed in the EPA risk > assessment: > ** In a chronic reproductive study of mallards, declines were seen > in number of eggs laid (-41%), number of viable embryos (-44%), and > number of normal hatchlings (-56%). A decrease in body weight of > adult males and females (males: -14%; females -15%) was also evident > and in females appeared in the first few weeks of exposure. > > ** American Cyanamid's testing shows chlorfenapyr to be persistent > in soils, with a half-life of one or more years. Applications made > to the same fields in consecutive years can result in a build-up in > the soil to as much 2.5 times the annual application rate. Such > persisting residues could contribute to levels of dietary exposure > higher than those suggested by a single year of application. > > ** Chlorfenapyr residues are found in avian food items including > weed seeds, insects and foliage. Levels of chlorfenapyr in avian > diets may be as much as 68 times higher than the EPA threshold for > reproductive effects, and EPA states that these toxicological > thresholds may be exceeded for up to five weeks after initial > application to cotton crops. > > ** The timing of chlorfenapyr applications coincides with critical > reproductive events for most, if not all, of the more than 50 avian > species that, according to American Cyanamid, are associated with > cotton fields. Many of the tested species are showing downward > population trends in cotton growing states. > > American Cyanamid has proposed numerous mitigation measures and > restrictions for use of chlorfenapyr; however, EPA believes that > such measures "still yield dietary exposure estimates that exceed > chronic toxicity thresholds for birds." In addition, EPA's risk > assessment does not include effects of ingestion of the chemical > through preening or via drinking water, dermal exposures or > inhalation of suspended particles. American Cyanamid also has not > provided a field study of chlorfenapyr that specifically addresses > avian reproductive effects. > > At least 13 pesticides documented as causing die-offs in migratory > birds are currently registered for use on cotton. The American Bird > Conservancy is concerned that the addition of another chemical with > evidence of reproductive risks for avian species is imprudent. > > Send comments to the EPA by February 19 asking EPA to deny > registration status for chlorfenapyr under Section 3 of the Federal > Insecticide, Fungicide, and Rodenticide Act (FIFRA) given its > reproductive toxicity for birds. In addition, call for EPA to > discontinue the registration process for all other applications of > chlorfenapyr. Comments that add scientific information on > chlorfenapyr and its particular effects on avian species are > extremely valuable, as are comments on the scientific soundness of > EPAUs ecological risk and/or economic benefit characterizations. > > Include docket number OPP-34162 and send to: > Public Information and Records Integrity Branch, Information > Resources and Services Division (7502C), Office of Pesticides > Programs, Environmental Protection Agency, 401 M St. SW, Washington > DC 20460. Email can be sent to opp-docket@epamail.epa.gov as an > ASCII attachment without special characters or encryption codes. > > Full text of the chlorfenapyr risk benefit assessment can be found > at: www.epa.gov/pesticides/reg_assessment. Additional information > can be found at the American Bird Conservancy web site: > www.abcbirds.org > > Source/contact: Kelley R. Tucker, Director, Pesticides and Birds > Campaign, American Bird Conservancy, 1250 24th St. NW, Washington, > DC 20037; phone (202) 778-9666; fax (202) 778-9778; email > ktucker@abcbirds.org. > > ====================================================== > Pesticide Action Network North America (PANNA) > 49 Powell St., Suite 500, San Francisco, California 94102 > Phone (415) 981-1771 > Fax (415) 981-1991 > Email: panna@panna.org > web site www.panna.org/panna/ > > To subscribe to PANUPS, email to majordomo@igc.org with the > following text on one line: subscribe panups > To unsubscribe send the following: unsubscribe panups > ====================================================== > > Wilbur Hershberger WHershbe@afrs.ars.usda.gov